Top Innovations
_
Last updated March 28th 2024.
This is the personal information processing policy (“Privacy Policy”) that governs how Top Innovations LLC and our affiliated companies ("Top Innovations", "we", "our" or "us"), use Personal Data (defined below) that we collect, receive and store about you in connection with your use of our website: www.topinnovations.co and any other website or application that we operate, or our partners operate on our behalf, (each, together with its sub-domains, content and services, a "Site"). Our Site may contain links to third-party websites and services that are not owned or controlled by Top Innovations. We are not responsible for the privacy practices or the content of third party websites, services and advertisements, and you visit them at your own risk.
As used in this Privacy Policy, the term “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you. Personal Information does not include information that is publicly available, de-identified, or aggregated.
Generally, we collect the following categories of Personal Information, which we use for the business or commercial purposes shown below. Note that the Personal Information we collect about you may vary depending on the Service and the nature of your interactions with us, and may not include all of the examples listed.
| Category of Personal Information | Purposes for Collection |
|---|---|
|
Identifiers, such as name, email address, mailing address, online identifier, Internet Protocol address, and other similar identifiers Personal records (which includes the information listed in Cal. Civ. Code § 1798.80(e)), such as name, signature, address, telephone number, driver’s license or state identification card number, education, employment, credit card number, debit card number, or other financial information Commercial information, such as products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies Internet or other electronic network activity information, browsing history, search history, and information regarding your interactions with our websites, applications, or advertisements Characteristics of protected classifications, such as gender and date of birth, as well as some sensitive Personal Information such as race or ethnic origin, religious or philosophical beliefs or union membership)Audio, visual, or similar information Inferences drawn from the other Personal Information we collect |
To allow you to participate in the features we offer on the Service To facilitate, manage, personalize, and improve your online experience To process your registration and/or upload your user-generated content To transact with you and provide services you request To communicate with you, including to respond to your comments, questions and requests For promotions, surveys, contests, sweepstakes, and other offerings To serve you tailored content and/or advertising, SMS/text messages, or offers For identity resolution To determine your location and manage digital content rights (e.g., territory restrictions) To fulfill other purposes disclosed at the time you provide Personal Information or otherwise where legally required or permitted To improve the Service and for other related business purposes To prevent and address fraud, breach of policies or terms, and threats or harm |
Biometric information, which may include sensitive Personal Information used to uniquely identify you |
To prevent and address fraud, breach of policies or terms, and threats or harm To improve the Service and for other related business purposes To fulfill other purposes disclosed at the time we collect Personal Information or otherwise where legally required or permitted For identity resolution |
|
Geolocation data inferred from your IP address and precise geolocation based on mobile device location |
To determine your location and manage digital content rights (e.g., territory restrictions) For identity resolution To serve you tailored content and/or advertising, SMS/text messages, or offers To improve the Service and for other related business purposes To prevent and address fraud, breach of policies or terms, and threats or harm |
As described in more detail in our Children's Privacy Policy below, some of our Services may collect Personal Information from children under 13, which may be considered sensitive under some state privacy laws.
In addition to the purposes described above, we may collect, use, and disclose Personal Information as required by law, regulation or court order; to respond to governmental and/or law enforcement requests; to identify, contact or bring legal action against someone who may be causing injury to or interfering with our (or others’) rights or property; to support any actual or threatened claim, defense or declaration in a case or before any jurisdictional and/or administrative authority, arbitration or mediation panel; or for other purposes described in any other privacy notice or with your consent. Additionally, we may use and disclose Personal Information to third parties in connection with a sale, assignment, merger, reorganization, or other corporate transaction relating to all or part of our business.
We collect the categories of Personal Information listed above from the following categories of sources: directly from you, from our affiliates (including other Top Innovations affiliated entities (“Top Innovations group companies”), and service providers that help us run our business, including data analytics companies, ad networks, social networks, internet service providers, and data resellers such as data management platforms. We also collect Personal Information via Tracking Technologies when you use our websites or mobile apps. Top Innovations uses cookies and other tracking technologies (such as web beacons and software development kits) to collect and store information about your interactions with our Service (collectively, “Tracking Technologies”). Our websites also support third-party cookies placed by our service providers and third parties, such as advertising partners. This means that our service providers and advertising partners can collect and use information regarding your interactions with our websites as further detailed below.
Top Innovations is giving you notice of the use of Tracking Technologies and your choices regarding them as explained in Section 10 below so that your consent is meaningfully informed.
A. Cookies and Other Tracking Technologies
Cookies are small files that a website transfers to your device through a web browser that enable the site’s or a third party’s systems to recognize your device and capture and remember certain information. Web beacons (also known as tracking pixels) are tiny graphics embedded invisibly on a webpage or in an email that may be used to deliver or communicate with cookies, to count users who have visited certain pages, and to understand usage patterns. In general, our websites use cookies and other tracking technologies as follows:
Cookies vary in how long they last. “Session cookies” terminate shortly after you terminate your internet session. “Persistent cookies” are stored on your device until a set expiration date. We use both session cookies and persistent cookies on our websites.
Please visit https://cookiepedia.co.uk for more information about cookies.
B. Analytics
Top Innovations uses analytics services such as, without limitation, Google Analytics. These analytics services may use cookies and other Tracking Technologies to help Top Innovations analyze Service users and how they interact with the Service. Information generated by these services (e.g., your IP address and other usage information) may be transmitted to and stored by analytics providers for purposes such as evaluating your use of the Service, compiling statistical reports on the Service’s activity, and providing other services relating to Service activity and other internet usage. Options for limiting our usage of analytics tools, including Google Analytics, are described in Section 10.
C. Session Monitoring
Some of the technologies used on our websites allow us and our service providers to monitor and analyze how visitors use our websites in order to better understand user behavior and improve our Services. When you interact with us online, information related to your browsing behavior (such as clicks, cursor movement, and scrolling) may be collected by us and our service providers.
D. Online Advertising
Our Service collects information about you to target advertisements to you when you browse the internet or use social media. More information on options for limiting online ads can be found in Section 10.
E. In-App Tracking Methods
There are a variety of Tracking Technologies that may be included in mobile applications, which are not browser-based like cookies and are be controlled by browser settings. Some use device identifiers or other identifiers such as “Ad IDs” to associate app user activity to a particular app and to track user activity across apps and/or devices. Features within our apps may allow you to disable some types of tracking in compliance law.
F. Third-Party Services and Social Features
Certain features on the Service permit interactions that you initiate between the Service and certain websites, platforms, applications, or services operated by third parties (“Third-Party Service(s)”), such as third-party social networks (“Social Features”). Examples of Social Features include: enabling you to send content such as contacts and photos between the Service and a Third-Party Service; “liking” or “sharing” Top Innovations’s content; logging in to the Service using your Third-Party Service account (e.g., using Facebook Connect to sign-in to the Service); and otherwise connecting the Service to a Third-Party Service (e.g., to pull or push information to or from the Service). If you use Third-Party Services, information you post or provide access to may be publicly displayed on our Service or by the Third-Party Service. Similarly, if you post information on a Third-Party Service that references us or our Service (e.g., by using a hashtag associated with Top Innovations or Top Innovations group companies), your post may be used on or in connection with the Service or otherwise by Top Innovations and Top Innovations group companies. Both Top Innovations and the third party may have access to information about you and your use of our Service and the Third-Party Service.
G. Online Chat
Some parts of our Service may offer interactive chat features to assist with answering questions, providing customer service, and similar purposes. When you participate in an interactive chat session, either with a virtual or live agent, the contents of the chat may be captured and kept as a transcript. By using these features, you understand that our vendors may process the information obtained through the chat to provide the Service on our behalf.
A. Disclosures for Business or Commercial Purposes
We may disclose each of the categories of Personal Information we collect to our service providers and contractors for the following business purposes:
We disclose sensitive Personal Information for more limited purposes, including: when necessary to provide our Services; services performed on our behalf related to the operation of our business and/or the Services; ensuring security and integrity of Personal Information; short-term, transient use; undertaking activities to verify or maintain the quality or safety of our Services; to comply with applicable laws and regulations; for safety and security; detecting, protecting against, or addressing malicious, deceptive, fraudulent, or illegal activity.
Affiliate Sharing. In accordance with applicable law, we may share your Personal Information with other Top Innovations group companies for the purposes for the purposes identified above (for example, for account authentication, account management, or marketing) and when it may be necessary or appropriate for the establishment or management of our relationship with you.
Business Reorganization. Top Innovations or any of its assets, may be sold, or other transactions may occur in which your Personal Information may be considered one of the business assets of the transaction. In this case, your Personal Information may be transferred to the purchaser, prospective purchaser, or joint venture partner to the extent permitted by law, either as part of the transaction or during any due diligence process.
Mandatory Disclosures and Legal Protections. We may share any category of Personal Information with government and law enforcement authorities and with other parties involved in, or contemplating, legal proceedings, to comply with a legal obligation, when we believe in good faith that the law requires it, to enforce our Terms of Use, or where necessary to protect our or others’ rights, property, safety, or security.
With your consent. If required by law, we may ask for your consent to share your information with third parties or for additional purposes.
B. Targeted Advertising, Sales, and Sharing of Personal Information
We may share each of the following categories of Personal Information with third parties such as advertising networks, internet service providers, certain data analytics providers, operating systems and platforms, social networks and Top Innovations group companies which may not share common branding:
Top Innovations does not sell Personal Information in exchange for money. Top Innovations shares Personal Information with third parties in compliance with the law to deliver targeted ads and other tailored communications to consumers, for certain type of analytics services, for purposes for which the recipient may use the information for our benefit and the benefit of other businesses, and for other similar reasons provided in this Privacy Policy. Some of these uses of Personal Information may be considered “sales” or “sharing” for targeted/cross-context behavioral advertising under US state privacy laws. If you are a resident of a California, Colorado, Connecticut, Virginia, or Utah and would like to opt out of these uses of your Personal Information, please see the instructions provided within the state-specific Sections below.
Top Innovations does not have actual knowledge that it sells the Personal Information of consumers under 16 years of age without affirmative authorization.
We keep the categories of Personal Information described above for as long as necessary or permitted for the purposes described in this Privacy Policy or otherwise authorized by law. This generally means holding the information for as long as one of the following apply:
Where information is used for more than one purpose, we will retain it until the purpose with the latest period expires.
A. CCPA Rights
If you are a California consumer, your rights under the California Consumer Privacy Act (“CCPA”) are set forth below.
If you are a California consumer who would like to submit a deletion, correction or right-to-know request, you can email us at legal@topinnovations.co. If you would like to opt out of sales of Personal Information or sharing of Personal Information for cross-context behavioral advertising, or if you would like to limit use of your sensitive Personal Information, please email us at legal@topinnovations.co. Please note that if you submit a request to delete, request to know or request to correct, Top Innovations will need to take reasonable steps to verify your identity before the request will be processed, which may include logging into your account or providing us with 2-3 pieces of Personal Information which we will match to information we maintain about you. You may designate an authorized agent to make a request on your behalf; however, you will still need to verify your identity directly with us before your request can be processed. An authorized agent may submit a request on your behalf using the webform or toll-free number listed above.
Right to Delete. As a California resident you have the right to request that Top Innovations delete Personal Information which Top Innovations has collected from you, subject to certain exceptions. Where we use deidentification to satisfy a deletion request, we commit to maintaining and using the information in deidentified form and will not attempt to reidentify the information.
Right to Correct Inaccurate Information. If you believe that Personal Information we maintain about you is inaccurate, you have the right to request that we correct that information.
Right to Know. You have the right to know what Personal Information we have collected about you, which includes:
Right to Limit Use and Disclosure of Sensitive Personal Information. You have the right to limit our use and disclosure of sensitive Personal Information to uses that are reasonably necessary to perform services, provide goods to you, or as otherwise permitted by CCPA.
Right to Non-Discrimination. California consumers have the right not to receive discriminatory treatment by a business for the exercise of their privacy rights conferred by the CCPA.
B. California Notice of Financial Incentive
In certain instances, Top Innovations offers benefits that may qualify as financial incentive programs (“FIP”) under California law. California consumers who opt in to the FIP may withdraw from the FIP at any time by contacting Top Innovations at legal@topinnovations.co. Participation in an FIP is voluntary. If you choose to participate in an FIP, Top Innovations may retain, use and/or disclose Personal Information it may have collected about you as described in this Privacy Policy, including identifiers, personal records, commercial information, internet or other electronic network activity information, geolocation data, characteristics of protected classifications (age and gender), and inferences. Top Innovations is required to explain how the value you receive from the FIP is reasonably related to the value that we receive from the Personal Information you provide to Top Innovations.
C. California’s “Shine the Light” Law
Top Innovations only knowingly shares personal information (as defined by California’s “Shine the Light” law), with non-affiliated third parties (i.e., parties other than Top Innovations group companies except as otherwise required by applicable law) for their own direct marketing purposes if you specifically opt-in, or are offered the opportunity to opt-out and elect not to opt-out, to such sharing at the time you provide personal information or choose to participate in a feature on the Service. If you do not opt in or if you opt-out at that time, Top Innovations will not knowingly share the personal information that was collected in connection therewith with such identified non-affiliated third party(ies) (or Top Innovations group companies where required by applicable law) for its/their own direct marketing purposes, but may continue to seek your consent to sharing with the same or other non-affiliated third parties (or Top Innovations group companies where required by applicable law) for their own direct marketing purposes from time-to-time. Each consent notice and opportunity will be treated separately so it is possible that you may consent to some sharing but not to others.
In addition, California residents may request information about Top Innovations’s compliance with the Shine the Light law and the Top Innovations group companies with which Top Innovations may have shared personal information for their direct marketing purposes by contacting Top Innovations here or by sending a letter to Top Innovations 1603 Capitol Ave. Suite 310 A228, Cheyenne, Wyoming 82001 (Attention: Privacy Program, Ethics & Legal Compliance Department). Requests must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that Top Innovations is only required to respond to one such request per customer each year, and Top Innovations is not required to respond to requests made by means other than through the provided e-mail address or mail address.
If you are a consumer who lives in Colorado, Connecticut, Virginia, or Utah (“Covered States”), you have the right to submit certain requests relating to your Personal Information as described below. Please email us at legal@thelightplus to submit requests for deletion, access, correction or appeals, or to opt out of targeted advertising. Please note that we may need to authenticate your identity before your request can be processed. For authentication, you may be asked to log into your account or to provide certain Personal Information that we will match against our records.
Right to Correct. You have the right to request that we correct inaccuracies in your Personal Information, taking into account the nature of the Personal Information and our purposes for processing it.
Right to Delete. You have the right to request that we delete your Personal Information, subject to certain exceptions.
Right to Access and Data Portability. You have the right to confirm whether we are processing your Personal Information, to access your Personal Information, and to obtain a copy of Personal Information you provided to us in a portable format.
Right to Opt Out. You have the right to opt out of the following uses of your Personal Information: (a) targeted advertising; (b) the sale of Personal Information; and (c) profiling in furtherance of decisions that produce legal or similarly significant effects concerning your economic situation, health, personal preferences, interests, reliability, behavior, location, or movements. Top Innovations does not sell Personal Information for money and does not profile individuals in furtherance of decisions that produce legal or similarly significant effects under applicable state privacy laws. To opt out of targeted advertising and/or non-monetary “sales” of Personal Information, please use the links provided above. If you are an authorized agent submitting an opt-out request on behalf of a consumer where allowed by law, please follow the instructions provided above and within our webform. We use commercially reasonable efforts to authenticate the identity of the consumer to whom the request relates and the authorized agent’s authority to act on the consumer’s behalf.
Right to Appeal. Sometimes we are unable to process requests relating to your Personal Information, in which case, your request will be denied. If you are a resident of a Covered State whose privacy rights request has previously been denied by us and you believe we denied it in error, you may appeal for reconsideration of your request via emailing legal@topinnovations.co.
Information for Nevada Residents. Nevada law provides residents the right to opt out of the “sale” of “covered information” to third parties, including but not limited to name, address, social security number, telephone number, email address, and other information through which a person may be contacted. Our uses of your covered information are not sales under Nevada law. If you have any questions or if you would like to receive notice by email in the event we should engage in “sales” of covered information under Nevada law in the future, please contact us using the contact information provided below.
Top Innovations is based in the United States. If you are using our Service outside the United States, please be aware that information we obtain about you may be transferred to and processed in the United States or other jurisdictions outside your own, and may be accessed by the courts, law enforcement and national security authorities in those jurisdictions. By using our Service or otherwise providing your Personal Information to us, you acknowledge and consent to the international transfer and processing of your Personal Information as described in this Privacy Policy. Please be aware that the data protection laws and regulations that apply to your Personal Information transferred to the United States or other countries may be different from the laws in your country.
7.1 Your South Korea Rights.
7.1.1 Procedure and Method of Destruction of Personal Information
Top Innovations destroys personal information without delay when the information becomes unnecessary, such as the lapse of the personal information retention period as outlined in section 6 or achievement of the purpose of processing as outlined in section 4 above.
If the personal information retention period agreed by the user has lapsed or the personal information needs to be kept in accordance with other laws despite the achievement of the purpose of processing, the personal information may be moved to a separate database (DB) or stored to be preserved differently. Separately stored personal information will not be used for any purpose other than the purpose of preservation unless it is required by law.
7.1.2 Destruction Procedure
The company selects the personal information for which the reason for destruction has occurred and destroys the personal information with the approval of the company's personal information protection officer.
7.1.3 Destruction Method
The company destroys personal information recorded and stored in the form of electronic files using methods such as low-level format so that the record cannot be reproduced, and personal information recorded and stored in paper documents is destroyed by shredding or incineration with a shredder."
7.1.4 Personal Information Protection Officer
Name: Legal Department (Privacy)
Email: legal@topinnovations.co (subject heading Privacy)
Address: 1603 Capitol Ave. Suite 310 A228, Cheyenne, Wyoming 82001
7.1.5 Notice on Overseas Transfer
| Company Name | Country | Purpose of Use |
Data | Transfer occurrence |
Retention period |
|---|---|---|---|---|---|
| Top Innovations LLC | Canada and United States | Account Service | As per section 1 | As per section 1 | As per section 4 |
Top Innovations does not knowingly collect Personal Information as defined by the U.S. Children’s Privacy Protection Act (“COPPA”) in a manner that is not permitted by COPPA. For more information, please see our Children’s Privacy Policy, which is incorporated into this Privacy Policy by reference. If you are a parent or guardian and believe Top Innovations has collected Personal Information from a child in a manner not permitted by COPPA, please contact Top Innovations via email at legal@topinnovations.co and Top Innovations will remove such data to the extent required by COPPA.
Any California residents under the age of eighteen (18) who have registered to use the Service, and who have posted content or information on the Service, can request removal by contacting Top Innovations via email at legal@topinnovations.co, detailing where the content or information is posted and attesting that you posted it. Top Innovations will then make reasonable, good faith efforts to remove the post from prospective public view or anonymize it so the minor cannot be individually identified to the extent required by applicable law. This removal process cannot ensure complete or comprehensive removal. For instance, third parties may have republished or archived content by search engines and others that Top Innovations does not control.
We take reasonable measures to protect all Personal Information we collect form loss, theft, misuse and unauthorized access, disclosure, alteration, and destruction. Nevertheless, transmission via the internet and online digital storage are not completely secure and we cannot guarantee the security of your information collected through the Service.
A. Accessing and Changing Information
If you have registered an account with Top Innovations, Top Innovations provides you with tools and account settings to access, correct, delete, or modify certain information associated with your account. Top Innovations will make good faith efforts to make such requested changes in Top Innovations’s then-active databases as soon as practicable. Further, we reserve the right to retain data as required by applicable law, and for so long as reasonably necessary to fulfill the purposes for which the data is retained except to the extent prohibited by applicable law.
B. Choices About Tracking Technologies
Tracking Technologies Generally. Cookies and tracking pixels, among other Tracking Technologies, may generally be blocked, disabled, or removed by tools available as part of most browsers. You can also manage the use of some Tracking Technologies such as cookies and tracking pixels by using Top Innovations’s Cookie Consent Tool. Please be aware that each website uses its own cookies, so cookie preferences should be set for each Top Innovations website. If you choose to use our Cookie Consent Tool, a preference cookie will be placed on your device in order to maintain your settings. If you later delete cookies from your device, you will also remove the preference cookie. Therefore, in order to remain opted out of Tracking technologies, you will have to go back to the Cookie Consent Tool and renew your choices.
Do-Not-Track Signals. Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no consensus as to what “Do Not Track” means in this context. Like many online services, Top Innovations currently does not alter its practices when it receives a “Do Not Track” signal from a browser.
Analytics and Advertising. In addition to exercising your choices through our Cookie Consent Tool, you may exercise choices regarding the use of cookies from Google Analytics by going to https://tools.google.com/dlpage/gaoptout or downloading the Google Analytics Opt-out Browser Add-on. You can personalize the ads you receive or opt out of ads from Google by visiting the Google Ads Settings page. You may exercise choices regarding the use of cookies from Microsoft by going to http://privacy.microsoft.com/en-us/privacystatement.
You may choose whether to receive some interest-based advertising by submitting opt-outs. Some of the advertisers and service providers that perform advertising-related services for us may participate in the Digital Advertising Alliance’s (“DAA”) Self-Regulatory Program for Online Behavioral Advertising. To learn more about how you can exercise certain choices regarding interest-based advertising online, visit http://www.aboutads.info/choices/, and http://www.aboutads.info/appchoices for information on the DAA’s opt-out program for mobile apps. Some of these companies may also be members of the Network Advertising Initiative (“NAI”). To learn more about the NAI and your opt-out options for their members, see http://www.networkadvertising.org/choices/. Opting out does not mean that you will no longer receive ads, but that the ads you see will no longer be relevant to your preferences. Also, if your browsers are configured to reject cookies when you visit these opt-out webpages, or you subsequently erase your cookies, use a different device or browser, or use a non-browser-based method of access (e.g., mobile app), your NAI / DAA browser-based opt-outs may not, or may no longer be effective.
Mobile Apps. With respect to Top Innovations’s mobile apps, you can stop all collection of data generated by use of the app by uninstalling the app. Also, you may be able to exercise specific privacy choices, such as enabling or disabling certain location-based services, by adjusting the permissions in your mobile device.
C. Choices About Communications
You can opt out of receiving certain promotional communications (emails or text messaging) from Top Innovations at any time by: (i) for promotional emails, clicking on the unsubscribe link and following the instructions provided, or changing your communication preferences within your account settings; and (ii) for text messages, following the instructions provided in text messages from Top Innovations (i.e., text the word, “STOP”). Please note that your opt-out is limited to the email address or phone number used and will not affect subsequent subscriptions. If you opt-out of only certain communications, other types of communications may continue. Even if you opt-out of receiving all promotional communications, Top Innovations may, subject to applicable law, continue to send you non-promotional communications, such as those about your account, transactions, servicing, or Top Innovations’s ongoing relationship with you.
Top Innovations reserves the right to revise this Privacy Policy at any time. Any changes will be effective upon the posting of the revised Privacy Policy unless otherwise stated. Your continued use of the Service indicates your consent to the Privacy Policy then posted. If you do not agree, please discontinue use of the Service and uninstall Service downloads and applications.
If you have any questions about this Privacy Policy, please contact Top Innovations:
By Email: legal@topinnovations.co
By Mail: 1603 Capitol Ave. Suite 310 A228, Cheyenne, Wyoming 82001
Copyright ©2024 Top Innovations LLC All rights reserved.
_
